HomeMy WebLinkAbout06-4628IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CACV OF COLORADO, LLC
Plaintiff
VS.
CORINA BROWN
Defendant
No. 01. '^/loz?) 0;"t a'
COMPLAINT IN CIVIL ACTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05331868
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CACV OF COLORADO, LLC
Plaintiff
VS. Civil Action No. (?(o _ ,C(LZ,p ei. L?sn , ,,?
CORINA BROWN
Defendant
COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the court without further notice for
any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may
lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
1. Plaintiff is a corporation having offices in 370 17TH ST.,SUITE 5000
DENVER, CO 80202-5622
2. Defendant is an adult individual residing at 109 LIGH'T'HOUSE DR
MECHANICSBURG,PA 17050 .
3. On or about SEPTEMBER 12 2002, Defendant duly executed a PA SIMPLE INTERST
VEHICLE TETAIL INSTALLMENT CONTRACT (hereinafter the "Contract"), a true and
correct copy of said Contract is attached hereto, marked as Exhibit "I" and made a part
hereof.
4. Pursuant to said Contract, Defendant took possession of the vehicle more particularly
identified in the Contract as a USED 1997 PONPIAC GRAND AM.
5. Pursuant to the terms and conditions provided by the Contract, the Contract was assigned to
Plaintiff.
6. Plaintiff avers that Defendant is in default of the Contract by having not made payment to
Plaintiff as promised, thereby rendering the entire balance immediately due and payable.
7. Plaintiff avers that a balance of $10,354.27 is due from Defendant as of JULY 11, 2006.
8. Plaintiff avers that the Contract between the parties provides that Plaintiff is entitled to
interest at the rate of 6.00% per annum.
9. Plaintiff avers that the Contract between the parties provides that Defendant will pay
Plaintiffs reasonable attorneys' fees.
10. Plaintiff avers that such attorneys' fees amount to $1500.00.
11. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or
refused to pay the principal balance, attorneys' fees, interest, or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendant, CORINA BROWN, individually,
in the amount of $10,354.27 with continuing interest thereon at the Contract rate of 6.00% per annum
from JULY 11, 2006, plus attorneys' fees of $1500.00 and costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL BE USED FOR THAT PURPOSE.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
William T. Molczan, E uire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W WR#:05331868
PENNSYLVANIA SIMPLE INTEREST VEHICLE RETAIL INSTALMENT CONTRACT DATE
Buyer (am Co-plyer) Name and Address (Includirp County and 21p Code) CREDITOR (Saes, Norns and Address)
'COMFNA `L BROWN CROWN FORD SALES, INC
109 LIGHTHOUSE DRIVE 2024 LINCOLN NAY EAST
MECHANICSBURG PA 17050 CHANBERSBURG PA 17201 •
yew the Buyer (pd c""ar, N wryl may buy the vehicle ascrand below for case erw CMdlL Tbe'Cash Prb• Yawn bebw - w ape
'Tale Bale Price' shown below Is the cmdl odes, By Yaap tlde bean. you ahaop to buy an credit under tla agreements, an do tCrd s
NewNsed Year and Make =1 OVW t Truck tbs.) I Vehicle Idardditalbn Number Use For Which
USED PONTIAC GRAND AM 1G2ME12T3VC839400 SIX P C Agd
Trada-in 1999 FORD s 13500.00 a 13181.48
' Year and Maa Gray Alaam, Mead Owing YOU MAY OBTAIN VEHICLE INSURANCE
FROM A PERSON OF YOUR CHOICE.
' •' 17012.37
1. Cash Price
$ (1) YOU ARE NOT REQUIRED TO OBTAIN
.................. _...... ...... _........ ..... _.»..._....,.,...._...... ............. CREDIT LIFE, CREDIT DISABILITY AND
2. Down Payment
M/A OTHER OPTIONAL INSURANCE. THIS
Third Party Rebme Assigned to Creditor..._ ........................ S CONTRACT WILL NOT INCLUDE THEM
Cash In
S
1;$rto )5_...S...Y7'S0b': DB....s....YY'91':B
J1B-5S
UNLESS YOU SIGN AND AGREE TO PAY
. Trade-in
$ THE PREMIUM.
Yin inn cox. ?e
318. 52
Total Doom
Pa
mord
S (2)
THIS CONTRACT DOES NOT INCLUDE
y
.................... _...__.... _.............. _..._..............
a LIABILITY INSURANCE COVERAGE FOR
a
of Cash
3. Unpaid Balance of Cash Pace (1 minus 2) ............... _.......
._ S
"
(0)
BODILY INJURY AND PROPERTY
port
0. Amounts geld on your baltall (Seller may be retaining a portion of tildes amounts)
' DAMAGE CAUSED TO OTHERS.
To Insurance Companies for
$ N/A
Credit Life Insurance (for loon of contract) ..... ..... ........... .
S N/A ..
Credo Olasbnlty Insurance (for term of contract) ...... :.......
rrenn Mho(Eatkr. ff, M/A
To Public Officials (I) for Ikene "" title (S 2I. 50 1. S
registration ($ M/)1 fees S 28.50-
?
O Credit Life N/A
.... .'. ., Insurer .
, :
W /A
.
. 00
(it) for filing lees $ .
.
$
209
70
243
20 Premium - Insured(s)
.
.
(l0) for fazes (not In Cash Price) $
$ .,
To for Messenger Service .....»......... $ ?
To-for
$ Signgttxe
CROMN FORD SAL% DOC FEE
To
N A
TTotal .................._........_..._?_........._.............._...__.......__..._....s?• 20(4)
5. Amount Financed 3 plus 1 .....:_...._......_._..._. ??
.........._"...._......_. S 8 C
tlDieebiHity' -N/A
Insurer
$ N/A
. :. Reemium. Insured
ANNUAL FINANCE Amount T9112111 of Total Sale Signature
PERCENTAGE CHARGE Flnanced PaymeMS Price
RATE
The cost of your
troth se, a yearly rate III* dollar amount
the credit will
wet you The amount of
MO pmrkBE W
you or on your
behalf 7be amount
you will haw!
Pled when you
ha
ve mW
sl The total mY
of you PXWMN w
credit.
Including your -
.. ... ..;, ..,
..
: I7 Typo of Insurance Term.
d
a
Portents ?
of s
Y-t+L
R.90 % S 4121:95 S 16992.05 S 21114.00 S 21432.52 '- IqB rBr Premium
y y K . r
fhymatSPl>IdYICE 4 plcrtlyh C
,pjgp'( `
1* ., ... Ure
Credit Uh and Crew DMWM Insurance, Bob,
for ins firm M ON P I ins sachem and
x
l
d
M
J
2
wish lam, #, 1. a .. •._..v
e
NYNagN ash a
• rat
ae s, epala
swn
BNen to you Mast'.
_ ? _ t•w _; -
You must Insure 0e, vleSCM. If a charge Is
shown belayt tla cMbor VAN is te wt' Ms
.. •„x'.,,._ covanpes allealea for ft firm shown.
Co=
based In
wall
t
o
n
1 l
. ,
oss, Wn
war
w
o
the Broke Of "wpm".
0
oh 0
$
Deductible
Co
iNe
Prepaynam: If you pay off your debt lady, you we not have to pay a penally. _
-
CWIMIOn
._
Lets Payment: You must pay a late chargoon.the paOarof sech-paymem-mclevadmam- .
than 10 days late. The charge M 2 percent of de, late amount or $50.00 whtehaver M Mss. . _
'O Frw ThaflCornbhad AadtlonY Cowrepe
Sectrity I as al: You are gtvMg a saaudty insisted M to vNacle being purchased. ? Towing are Labor
Cantrset Please ash ads contact for aOAtional idamallm on sedudty Into" , nonpa 1
tlafalA
tha dpm fo require mpsyrllant of you debt In full before the altedaetl-0W
a 13 Temp NO mans):. -OLiso
.
w
.
.?
..
,
;
lly
plepaynherhl paM . v.
P..,4
.
COIaraAC1AL V1NIrCLES: TM c argemoa t Mtheabase bittar MeepaymNte apprise wham tla welsh than vbbouharrweaigmt gEO180covehimser pYnde a?mae«yyou plry Ise Mere aftilM porrwnaach psymard?r? vehicle more mm to.aya late. The wage M 4 poreerd leas We amount or sm, whit ace is Ice.
I you w wt met your caveat obggW WS, you may has to wNwis that you se, launching under rem contract
as wee N bah Pus and goods Pa on to VeNcle and am" or goods reeaad for to vlewb.
NON-MODIMATION DISCLOSURE
Any chaps in pile contract must be M wrong ay ci signed by you and the Creditor.
1?`?'• ?O.9UV'ER:
II
Do not sign this contract In blank.
You are untitled to an exact copy of the contract you sign.
Keep it to protect your legal rights
?,m.,,,.n.. D (•1n?r.eM?
QUESTIONS?,
PLEASE CALL US AT 1-800-727-7000
' uo•a9t
SODS\S1\e0
A. Payments and Sumt
payments when they are dL
time without penalty. This
actual finance charge you
payment patterns. The act
disclosed Finance Charge I
the scheduled dates or in I
pan of the Finance Charge
The Creditor Sams are Finar
Percentage Rate to the J*
time the unpaid Amount Final
repossessed, you will not he
unless the Creditor agrees.
S. Security Interest You gi
1. The vehicle and at pans
2. All money or goods ewe
3. All insurance premiums I
This secures payment of all
also secures your other agree
C. Use of Vehicle - WART
the vehicle and obey an laws
the vehicle, and you must ke
You will not use or permit it
United States, except for up
witlem the prior written cons
of a type normally used for
the whicie's manuladurel
service contract covering U
dale of thig„Fomrect, t
merohardabi nd Mness
the vehiots. Otherwise, you
are no such Implied waman'
D. Insurance: You must insi
loss or damage to the vehk
type and amount of insuranm
insurance or service contra
refund from what you owe.
Insured, you Est pay h
destroyed.
If a charge for vehicle Inst
Creditor will try to buy the m
The Creditor is not table, d
oovereges cost more than th
Creditor may buy them for I
credit for the amount shown.
will give you credit for to am
to the last payments due.
Charge: You will
lYan of each payment mk
charge Is shown w the front.
not excuse your default or
payments after they are due.
forth In this contract, ft there I.
ADDITIONAL AGREEMENTS
y Notice: You must make. of " F. Default: You will be in default It
You may prepay your debt at any
' hp qs r#r te when r
1. You do not make a pa
?
wz s
2. Ycu gays tabs m mi
application totaling to this
a 44}Qc1 I'
ih 3. Your vehicle is sazed)lilli Btal, ANN63016N6N0
than the Scheduled amount. The aumority and is nor promptly and unconditionally
me fled to the earned and unpaid returned to you; or '
d men to the Amount Financed. 4. You file a bankruptcy petition or one is fled against le
e Charge by applying the Annual 5. You do not keep arty oter promise in this contract.
I AmI0US?
4
' h you are in dekp 4MLgntdltm may req pay of
I
8
tlIG?d
a a right to reinstate the contract
contra the unpaid Amount Financed, the earned A part
harge and all other amounts due under this cm
in ?
8l re
0¢
Q Tylpossess (lake back) the vehic1615111H Ngedal
take goods found in or on the vehicle when repossesser
P the Creditor a security Interest in: hold them for you.
r oiler goods pm on the vehicle; -
You a notice' The
If the vehicle is token back, he will send
Id fm gre vehi?; and TE. S10T1 It wl
will
soy that you may redeem (buy balk) the v9a
d service contracts financed for ? r
ow the amount needed to redeem. You may y retleer
show
\y
F vehicle up to the time the Creditor sells it or agrees to se
4 It
nwnts you owe in this can?
rents in this contract `n you do not redeem the vehicle! it will be sold.
( TheStreDrt?411 use QrQe'A,awyfrom t{§WJ the al
kNT1ES: You must take care d expenses, to pay the amount- still owed on this cm
1 using it Y. pray not?•II?1tam Expenses paid as a drect result of having to retake the w
o If has troth the dalmcal,ppggc hold it for sate, and sell it are, as permitted try law, al
use of the vehicle a
o 30 days; in Canada or Mexico,
-
2 expenses. Lawyers' fees and legal coats pammed by Is
allowed too. The Creditor will pay you any money I
A of
Me b
itoi. N the vehicle Is surplus). You will pay any money still owing after the safe
arsmsl tees and the Credpap or
Creditor. If you do not pay this.amount when the Creditor
extends a wrBhn we or
the Cretlitm may charge you interest at the highest lewfL
wthicle witty, 90 No
E until you pay.
of
u get Implied war
x a pordisgIor ees Screening
mderstand ratand, and agree that at there S
020. Ciarraroh T gp p(dact Ford Moot[ Company ale
moount, call 1• 7.7000. T t Pennsylvania.
IN1
a yourself I ge Cred?4T
,Z Creditor must a e to INS contract. If the law doge n6&t allow all of the pre
in this oordrW,.gBSones that are not allowed will be von
rest of this contract will still be good.
If the Creditor obtains a mfbhW on
s, the Creditor will subtrdtl .Mil
Whether or not thee Is
We Is Shown on to front the
rages chocked for the term shown.
ugh. N he cannot do so. it these
amount shpvm for insurance. the
shorter tern or he may give you
he cannot buy any insurance, he
lm shown. The credit will be made
N it b lost, S W
H 20.seea1
rve to pay a late M?rSe &fLthe
le mme non tentday¢78p, 11kp
cceptance d a lets p e
lean Mat you can keep making
Is Creditor may. take the steps set
333 700 ,23JA2 ON09 NNOR7
of .
,
N -
NOTICE - ANY HOLDER OF THIS CONSUMER CREI;IT
CONTRACT IS SUBJECT TO ALL CLAIMS ),.VD
DEFENSES WHICH THE DEBTOR COULD ASST: T
AGAINST THE SELLER OF GOODS OR SERVICf.S
OBTAINED PURSUANT HERETO OR WITH '.`i`E
PROCEEDS, HEREOF. RECOVERY HEREUNDER?3Y
THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID i 3Y
THE DEBTOR HEREUNDER.
Used Motor Vehicle Buyers Guide. If you ere buying e I ad
vehicle with this contract, federal regulations may requir a
.*MU BuyM 411111 to be dk;HayhBldn the winlbw?j jhe
vehicle. THE INFORMATION YOU SEE ON THE
WINDOW FORM FOR THIS VEHICLE IS PART+)F
THIS CONTRACT. INFORMATION sly WINOCiW
FORM =CT ANY C,QJ?TpA/IY .PROVISIf^+YS
IN, THE OF SAW"
ALE: I
AN
r Sdsm to a
r Qtllaranter
drone who
rroiuit owed
more of the
Guarorow
K mare a oa m In.w w
vehicle described on the Word of this contact to the Buyer; on credit, each person who signs b
. payment of this tamed. This memo tal N the Buyers Ielb to pay any money that is owed
as a guarantor win pay it when asked. Each parson who cigne below sprees that he will be 11
N one or mare other persons aim signs Ibis Guaranty. He also agrees to be noble even 0 the.
dnh8 (a) gives the Buyer more me to pay one, or-mom payments, or (b) gives a release in fWl q
or (c) releases any security, Each Gwrentgr also states that he has received a completed cop
the time of sighing. .1 • .. .
Address
Address -
raor e. w.nt
USED 1 lPOIrYY f7IAC GRAND AN 1G2NE12T3VC839400 1°Yr Commer°?°°°r
? del
Trod" 1999 FORD a 13500.00 a 13181.48 A
year wd MGM Groom Allowance Amount Owing YOU MAY OBTAIN VEHICLE INSURANCE
FROM A PERSON OF YOUR CHOICE.
17012.37
1. Cash Prim
$ (t) YOU ARE NOT REQUIRED TO OBTAIN
............................ _....
............................ .................... ........ CREDIT LIFE, CREDIT DISABILITY AND
2. Down Payment
N/A OTHER OPTIONAL INSURANCE. THIS
Third Party Rebab Assigned to Cresson ............. _........... $ CONTRACT WILL NOT INCLUDE THEM
.._.. $
Cash Down P M .....
-3SB-SZ
1990?ON15 12'SYitf:1SC....s....YJrar.-XS UNLESS YOU SIGN AND AGREE TO PAY
Trade-In .
S
$ THE PREMIUM.
row w,d wit noon wawrw w,w?w ors .
318
(2)
Tab) Down
ant........ _.......... _......................... _..................... S _
._
INCLUDE
THIS LIABILITY CONTRACT DO INSURANCE ES NOT COVERAGE FOR
a of
3
T61137115
T61137115
3. Unpaid Banana of Cash Prim (1 minus 21 ............. ............. _....... $ (S)
e. Amunb paid on your b~ (Selbr may be retaining a portion of these amounts) BODILY INJURY AND PROPERTY
DAMAGE CAUSED TO OTHERS.
To Insurance Companies for
N/A ,
Credit Life insurance (for term of contract)
$ .
Credit Disability Insurance (for tans of contract).............
[Term thh (Eetl t9,?If MIA
To Public OM ebb (0 for license ( "oa) title (S `• 50 8
8 N/A feesS f°•'°
ro Public i .
? Credit Life WA
':- Insurer
(
(i) for in 'I; feea S ?• 00 $ N A -? .
(iii) for Imes (not in Cash Prim) f 209.70 S 2l3. 20 Prendllm • Inwred(6) .
.
To for Mpasnpsr Sarvba _ .............:. Sw7A
to for S A Signature
To CROaN [ORD SALB PEE $ 55.00
?T
TTotal ...................................roe................. .......... _.............. ..... _.._. $ 20 (4)
S. Amount Financed 3 plus 4 ...................... $ S 2• S Credit
? Disability =. N/A
Insurer
P
i
I
d
rem
um
nsure
ANNUAL FINANCE Total of Total Selo Signature
CHARGE P
t P
ice
PERCENTAGE
RATE The eabr amount
no can of your Ne crass sim
teas se a yearly rate cost you
provided to
on
7
L aymen
s
ills erwnrnt
you will haw
paid when you
hew made an r
The totsl•oost
of your pumhses a
credit.
mcewng your
..
Type of Iniurance Tenn
?
ededuiad
psy? dawn m
eft 31rl52 -$
8.90 % S 4121,95 $ a 21114.00 f 23432.52 - ;;, Meurer Premium
`..Payment
" , .. .... re
RAYfadt Md .
' am dam
Vdgr plan 3 d ribs la 4 credit US, and Coda MaabeNy Insurance M
for the term of the comrael TM amour and
h
lt
t
I
averages an s
own
n a mo
s r agreemen
glean to you today.
a j.
f ` ° the
Charlie
Yaloen the`-.reditwill by b hiy tla
th
f
1
n
• hpyeragae Cnatwp
e blrll s
or
10yI1L
Covrasse will be bwd on the am war of
.
"N
l
tl
, but not non than
the
m
o
on p?
the "
..
:
Comprehensive CI $. DedIlm"
Prepayment a you pay off your debt harp you will not hew
pay e
penely. 1o
- -- ?
lo
a
LabPaymsnt: You must.wy is Isla dem o on.tho.portion of each .00 whi hexer is to " '
than 70 tlsyi'bta. TM deeps b 2 wranl of tlhe late arro arinoum or BSO.OD whichever is loss. p . n
°
"
? Rrs• 7haa-Crn1oinad Acidtional Coveralls
Security Interest: You are prop a sseudty Irlbwest N the vehicle belrq purchased. ? Towing and tabor
Contract: Plana w dos contract for addaarW Inlamadon on wuray Imanat, nonpa
your debt in tun before the sledded date, and
detW4 tM right
vim repayment of ? Tom N/A Mores (Esdmam)
.
- -
PnwYment Pon -
r Prerrsun $ N/A
COMINRGAL VEMCLa3: The dogs down in the above bit for lots poyntmts applies whom ae vowd,
Mohamed has a ims vaNmW solos of lee than p155..00D powalL a DN VeNds you p ohassd has • gran _
of each payment rsoeNed
whimaw 110 h days lale T. The qa Is pantos M Idea Isb snnowi m son the w wwiq? Is loss of 15"ll - or 014M. YOU a We
rope sun
If you do at mest your caned obfy5on, you may loss the vahals thol you am flow" under 1Na grant,
as wen as both Pero and goods Put on the "Noe ant money or goals wahad br fM valise.
NON-MODIFICATION DISCLOSURE
Any Clmge In rob coned must be in rideg ant signed by you aid Me Creditor.
Do not sign this contract In blank
You are entitled to an exact copy of the contract you sign.
Keep R to rotect your legal rights.
"AmfD?1n?Mn R. (3 tt lM?
BUYER son (00) BUYER SIGNS
copy
Pc 1raTr ow r Iowa. Parbw wry eoT r,..a1 / af! BACK Poll ADDITIONAL AGREEWNT'6
OUESTIONST
PLEASE CALL US AT 1-800.727.7000
00401
contract
GRIMMAL
B.
C.
of
D.
It
to
doge Rate to tre U*aid Amourll,FJBggSa 19,1 =1
is unpaid Amount Financed is oad1tt331144rtTddilAAti?J''11((''MM +irt? s
sued, you will not have a right to reinstate the contract
the Creditor agrees. 80.181E 1
?curtry Interest:, You gave the Creditor a security interest in:
'he vehicle and all parts or other goods put on the vehicle; -
UI money or goods received for the vehicle; and i'L . S 101.1
MI insurance premiums and service contracts financed for you.
scores payment of all amounts you owe In this oonVg . It
mums your other agreements In this contract
52.81C
s of Vehicle - WARRANTIES: You must take care of
hicle and obey all laws in using It. YIOU may 110tr4lSiI Eent
hide, and you must keep it free. from the dafine.o( Alai
III not use or permit the use of the vehicle ou eP
States,, except for up to 30 days in' Canada or Mexico,
t the prior written consent of the Creditor. N the vehicle is
rps normalty used for personal use and the CradJRgR or
Mlle's manufacturer, sxtaeuls a written or
e contract covering the vehicle within 90 aiys
of the;?`` ..c.amracL You get implied warren of
iantalal d fitness for a portledler purpose covering
rhic s. Otherwise, you understand and agree that there
r such Implied warrant)t}gH
rurence: You must Ireure yorrrsaN d the Cmdltorr*A&
r damage to the vehicle. The Crerlltor must app he
nd amount of Insurance. If the Creditor obtains a relbhg on
not, or service contracts, the Creditor will subuddl.1"
from what you owe. Whether a not the voll Is
You you A"st Pay for It It R is lost, . S or
ryad. 20 . S?Pd 1
herge for vehicle insu/%o is shown on the front, the
Tr will try to buy the coverages chocked for the term shown.
:reditor Is not liable, though, If he cannot do co. if these
rges cost more then the amount shown for Insurance, 0 s
N may buy them for a starter term or he may give you
for the amount shown. If he cannot buy any insurance, he
re you credit for the amount shown. The crew will be made
last payments due.
r
is Charge: You will have to pay than late pa
l of each payment t made mote th mlen: ff':dfaffh6tlbBbs
I is shown you on the hoot.. Acceptance y oou laic ps
cuss your defeat e. mean mean that at you cep keep making
his after they are due. the Creditor may take the steps set
I this contract, t there is any default.
If you are in deIRRIL(MR0fi dtor may req pay 49 0
the unpaid Amount Financed, theeemed w al part of the
he v icI under this contract.
Finance Charge and all other am'
04{ IWImpossess (take beck) the Punts du uncle NAthl also
take goods found In or on the vehicle when repossessed and
hold them ft. you. 11
It the vehIde le taken back, he wit send you a notice. The notice
will say that you may redeem (bud' back) the vehicle. It wiR also
stow the amount needed to redeem. You may redeem the _
vehicle up to the time the Cre0tq( sells it or agrees to sell it. If
you do not redeem the vehicle, Mill be sold.
The?ni use Q?e-W!11orn NWl9gsl the allowed
expenses, to -pay the amount lstill owed on this contract.
F-xpennees paid as a direct recoil ot having to retake the vehicle,
hold it for sale, and sell it are, Iis permitted by law, allowed
expenses. Lawyem' fees and legal costa penniitad by law are
allowed, too. The Creditor will ?beyI you any money left (a
surplus). You will pay any money All owing after the sale to the
Creditor. If you do not pay this . arflount when the Creditor asks,
the Creditor may charge you interst at the highest lawful rate
until you pay. .
02GSf? 11 T OAj:omjeot Ford M
acoounL all 1• 27-7000,
to this contract. If the law do&
in We contrad6. 96Sones that ar
rest of this contract will still be gr
Gpedk Company about this
is of Pennsylvania. applies
allow all of the agreements
of allowed will be void. The
333 000
05101 HHUH3
NOTICE • ANY HOLDER OF THIS CONSUMER CREDIT
CONTRACT IS SUBJECT ?TO ALL CLAIMS AND
DEFENSES WHICH THE D BTOR COULD ASSERT
AGAINST THE SELLER OF GOODS OR SERVICES
OBTAINED PURSUANT H qRETO OR WITH THE
PROCEEDS
HEREOF. REC OVERY HEREUNDER BY
.
THE DEBTOR SHALL NOT EX CEED AMOUNTS PAID BY
THE DEBTOR HEREUNDER. 1 1
Used Motor Vehicle Buyers Gu ide. It you are buying a used
"
vehicle with this contract, leder l regulations may require a
s
.!poll" Buy&b Q®N to be dli) gaymldn the wlrODWOW the
vehicle. THE INFORMATIO N YOU SEE ON THE
WINDOW FORM FOR TH14 VEHICLE IS PART OF
THIS CONTRACT. INFORMA TION?p? THE WINDOW
FORM O ES ANY C QNTRlN9Y PROVISIONS
,KjTHE C CT OF SAL ."````
0
Soog\S
A\H
., A\H
A\H
GUARANTY '
10 0W89 the SBfier to 11 the vehicle described on the front of this contact to the &lyw on credit , m person Nh0 sign below as
?'Cxuerardor' gwreMaes the. payment.01 he comma This means hid it the Buyer laik to pay any money that is owed.on this
:oMrea, each cane who signs es a guarantorwig pay t whwn asketl. Each pemm who signs below a? ees Met he wiR be Ilable for
is
whole Amount owed wen If are or mare other Persons she slgna.thle Guaranty. He also agrees td, be Roble even If the.Creditor
l m cep, or more of gm Mbwkg (a) ghme the Buyer moretkne to pay one or tae payments, a (b) a release in full grin part
: any of the oiler Guerinlonc, or (c) rM»eee any security: Each Guareraor also states that he has mc Wed a completed copy of this
:orltreet and this Guaranty.n the time of signing. ..,
uarantor Address .
'luarentor Address
nox, oew Prsw•ra+e•str aoT lr w.rt -
J7 1` t.
.. h.
. ?.' ? . ??••. . `?1 .2I3I41A2 OA03 NNOA]
VERIFICATION
The undersigned does hereby verify subject to the penalties of
18 PA C.S. 4904 relating to unsworn falsifications to authorities, that he is
John Becker, Authorized Agent of CACH, LLC, plaintiff herein, that he is
duly authorized to make this verification, and that the facts set forth in the
foregoing Complaint are true and correct to the best of his knowledge,
information and belief.
John Becker
This law firm is a debt collector attempting to collect this debt for our client
and any information obtained will be used for that purpose.
WWR#
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-04628 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CACV OF COLORADO LLC
VS
BROWN CORINA
GERALD WORTHINGTON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
BROWN CORINA the
DEFENDANT , at 1100:00 HOURS, on the 16th day of August 2006
at 109 LIGHTHOUSE DR
MECHANICSBURG, PA 17050
JOYCE BROWN, MOTHER
by handing to
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff'; Costs: So Answers:
Docketing 18.00
Service 10.56
Affidavit
.00
Surcharcre 10.00 R. Thomas Kline
.00
38.56,/ 08/17/2006
9WELTMAN WEINBERG REIS
Sworn and. Subscibed to / By:
before me this day Deputy Sher' f
of ,
A. D.
IN THE COURT OF COMMON PLEAS 01: CUMBERLAND COUNTY, PENNSN'LVANIA
CIVIL DIVISION
CACV OF COLORADO, LLC
Plaintiff
vs.
CORINA BROWN
Defendant
No. 06-=1628-CIVIL TERM
PRAFCIPL FUR DEFAULT 1UDGMFNT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OE
TIIIs PARTY:
W1L.L.IAM 1. M01,CZAN, ESQU1RY1
PA I.D.447437
Weltman. Weinberg & Reis Co., I.Y.A.
2718 Koppers 13ldg.
436 Seventh Avenue
Pittshurgh. PA 15219
(412) 434-7955
W WR405331868
Judgment Amount S 11,988. 73
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED F012 'T'HAT PURPOSE.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CACV OF COLORADO, LLC
Plaintiff
vs. Civil Action No. 06-4628-CIVIL.TERM
CORINA BROWN
Defendant
I O 'I HE PROTHONOTARY:
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, CORINA BROWN above named, in the default of an Answer.
in the amount of $': 1,988.73 computed as folloNcs:
Amount claimed in Complaint
$10,354.27
Interest from 07/11/06
at the legal interest rate of 6.00% per annum $134.46
Attorney's fees
TO'T'AL
$1500.00
$11,988.73
I hereby certify that appropriate Notices of Del-atilt, as attached have been mailed in accordance with PA
R C.P. 237.1 on the dates indicated on the Notices.
WFLTMAN, WEINBI:RG & REIS CO., L.P.A.
By:
\V1LLIAM T. MOL.-'- ESQUIRE
PA L.D.#47437 I,
Welumn. Weinberg & Reis Co.. L.P.A.
2718 Koppers 13Idg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W WR#05331868
Plaintiffs address is:
c,0 41 elunan. Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 109 LIGHTHOUSE DR
MECHANICSBURG,PA 17050
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CACV OF COLORADO, LLC
Plaintiff
CORINA BROWN
Defendant(s)
IMPORTANT NOTICE
TO: CORINA BROWN
109 LIGHTHOUSE DR
MECHANICSBURG,PA 17050 /-,
Date of Notice:
?_ c?? _
WWR : 05331868
Case # 06, - ?ff C E L.--Te(bv
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU.
UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A
JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR
TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE 14AY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013 r
(717) 249-3166 :.,A A A
BY: A JYV v?
JAMES W_ARMBRODT, ESQUIRE
PA I . D'. 1442524
WELTMAN/ WEINBERG & REIS CO., L.P.A.
2718'KQPPERS BLDG, 436 7TH AVE.
PITTSARGH, PA 15219
1N THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL [)]VISION
CACV OF COLORADO, LLC
Plaintiff
r<.
CoRINA BROWN
Defendant
Case no: 06-4628-CIVIL TERM
NON-MILITARY AFFIDAVIT
The undersigned, who first being duly sworn, according to law, deposes and states as follows:
That lie/she is the duly authorized agent of the Plaintiff in the within matter.
Affiant further states that the within Affidavit is made pursuant to and in accordance Nrith the
Scrvicemcmbers' Civil Relief Act (SCRA), 50 U'.S.C . App. § 521.
AI,iant I,urther states that based upon investiuation it is the affiant's belief' that the Defendant. CORINA
BROWN is not in the military service.
Affiant further states that this belief is supported by the attached certificate from the Defense Manpm cr 1)ata
Cunt,.:r (DMDC), which states that the Defendant, CORINA BROWN is not in the military service.
Further Affiant sayeth naught.
AFFIAN"I'
SWORN TO A 4D SUBSCRIBED i,&p presence this day
A,4? QD0JA 77COMMONWEALTHPENNSYLVANIA
Notarial Seal
'm t
>
N TARY PUBL J. Kelly, Notary L`
=burah, Alteghe
Ssion Expires
nnsylvania Assocwic ---o5
This law firm is a debt collector attempting to collect this debt for our client and am information obtained will be
u,ed for that purpose..
R_ccluest I-or Military Status
Department of Defense Manpower Data Center
Military Status Report
pursuant to the Servicemembers Civil Relief Act
Page 1 of 2
SEP-27-2006 08:18:54
I Last Name First/Middle Begin Date Active Duty Status Service/Agency
13ROWN CORINA Based on the information you have furnished. the DNIDC does not
possess any information indicating that the individual is currently on
active duty.
t lpon searching the information data banks of the Department of Defense Manpower Data Center, based
cn the information that you provided, the above is the current status of the individual as to all branclics
of the Military.
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
'I lie Defense Manpower Data (:enter (DMDC) is an organization of the Department ol'Defense that
maintains the Defense Enrollment and I',ligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
'I he Department of Defense strongly supports the enforcement of the Serviccmembers Civil Relief Act
[70 iJSCS Appx. #167;#167; 501 et scgj (SCRA) (formerly the Soldiers' and Sailors' Civil ReliefAct of
1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member. friend, or representative asserts in any manner th?a
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongdN
cncouu-aged to obtain further verification of the person's active duty status by contacting that person's
Military Service via the "defenselink.mil" U RI. provided below. If you have evidence the person is on
active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA
niay be invoked against you.
I l'you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle
name), you can submit your request again at this Web site and we will provide a new certificate for that
cl uery.
'I his response reflects current active duty status only. For historical information. please contact the
Military Service SCRA points-of-contact.
See: http:/'w"w.defenseIInk. miITaq/pis,'PL`U>tiLl)R.11tm(
\VARNING: This certificate was provided based on a name and Social Security number (SSN) provided
littps://www.dmdc.osd.mil/scra/owa/scra.prc_ Select 9/27/2OOo
I e quest j"or Military Status
Page 2 of 2
h-y the requester. Providing an erroneous name or SSN "ill cause an erroneous certificate to be provicled.
keporl lD: BOYUIXQIVDKY
http,)://wow.dmdc.osd.mil/scra/okva/scra.prc_ Select 9/27/2000
n ?
e
?TST.i
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL DIVISION
CACV OF COLORADO, LLC
Plaintiff
vs. Civil .Action No. 06-4628-CI` IL "TERM
CORINA BROWN
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the tollowin,)
Order or Judh-ment was entered against ynu
L) n (5c-4- __ IPC 24
(xx) Assumpsit Judgment in the amount
of 511,988.73 plus costs.
( ) Trespass Judgment in the amount
of's plus Costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration
will be suspended by the Department of Transportation, Bureau
of Traffic Safety. Harrisburg. PA.
(xx) Intry ol'Judgment oh
( } Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
B?:
PRO" ONO LARY }
CORINA BROWN
109 LIGHTHOUSE DR
ME( HANICSBURGYA 17050
Plaintiffs address is:
c/o Weltman. Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`' Avu1Ue, Pin,burgh_ PA
1-888-434-0085
f ( '?
4
II
IN THE COURT OF COMMON
II
i
CACV OF COLORADO LLC
Plaintiff
vs.
CORINA BROWN
Defendant
COMMERCE BANK,
Garnishee,
AS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
No. 06-4628-CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT and LEVY)
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05331868
IN THE COURT OF COMMON
CACV OF COLORADO LLC
Plaintiff
VS.
CORINA BROWN Z lei h Act Ori V
Defendant
COMMERCE BANK,
Garnishee
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution) i
I . directed to the Sheriff of Ct
2. against CORINA BROWN,
3. against COMMERCE BAN
4. Judgment Amount
Interest
Costs
SUBTOTAL:
Costs (to be added by Proth
EAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Civil Action No. 06-4628-CIVIL TERM
Z-7 , 0 ecncy-,vt ins +o ? rt? 10A
Mcc:.hakitcsbcjr 9 /70 a
t
FOR WRIT OF EXECUTION / '
1t S,? L-(,t' J C'I \Ax' t 1 to xx eta"
l?r ?? L? )-QZ7,1?1 C?tcrviicSb? 1 0 ?c? . Lei
ie above matter... rl 4 VLL
cl,
JJ ?
BERLAND County:
Garnishee
$ 11988.73
$ 419.77
$ 12408.50
Y) $
WELTMAN, WEINBERG & REIS CO., L.P.A.
W
By:
William T. Molczan, Es uire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05331868
4,-7)
ro
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVF NIA) NO 06-4628 Civil
COUNTY OF CUMBERLAND) ( CIVIL ACTION - LAW
i
TO THE SHERIFF OF CUMBERI
To satisfy the debt, interest and
From CORINA BROWN, 82 Ll
(1) You are directed to levy upon tl
DEFENDANTS PROPERTS
(2) You are also directed to attach
of COMMERCE BANK, 4860 C
GARNISHEE(S) as follows:
n n COUNTY:
on due CACV OF COLORADO LLC, Plaintiff (s)
JD DRIVE, LOT 27, MECHANICSBURG, PA 17050
p operty of the defendant (s)and to sell LEVY ON ANY/ALLOF
A 82 LINDA DRIVE, LOT 27, MECHANICSBURG, PA 17050.
he roperty of the defendant(s) not levied upon in the possession
ISLE PIKE, MECHANICSBURG, PA 17050
and to notify the garnishee(s) that: ()
paying any debt to or for the account o
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) 01
of anyone other than a named garni he,
garnishee and is enjoined as above otat
Amount Due $11,988.73
Interest $419.77
Atty's Comm %
Atty Paid $130.06
Plaintiff Paid
Date: JUNE 22, 2007
attachment has been issued; (b) the garnishee(s) is enjoined from
he defendant (s) and from delivering any property of the defendant
Ivied upon an subject to attachment is found in the possession
you are directed to notify him/her that he/she has been added as a
L.L. $.50
Due Prothy $2.00
Other Costs
C s R. Lon
(Seal)
By:
Deputy
REQUESTING PARTY:
Name WILLIAM T. MOLCZAN? E
Address: WELTMAN, WEINBERG
2718 KOPPERS BUIL I
436 SEVENTH AVEN E
PITTSBURGH, PA 15419
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 47437
& REIS CO., L.P.A.
WWR#05331868
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CACV OF COLORADO LLC
Plaintiff
vs.
CORINA BROWN
Defendant
and
COMMERCE BANK
Garnishee
No. 06-4628-CIVIL TERM
AS,Z6-5 -le
INTERROGATORIES IN ATTACHMENT
COMMERCE BANK
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR405331868
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CACV OF COLORADO LLC
Plaintiff
vs.
CORINA BROWN
Defendant
and
COMMERCE BANK
Garnishee
Civil Action No.: 06-4628-CIVIL TERM
TO: COMMERCE BANK Suggested Reference No.: XXX-XX-1174
4860 CARLISLE PIKE
MECHANICSBURG PA 17050
RE: CORINA BROWN
82 LINDA DRIVE LOT 27
MECHANICSBURG,PA 17050
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure to do so may result in Judgment against you.
B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of
Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes
into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the
resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the
time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the intervening period.
INTERROGATORIES IN ATTACHMENT
1. At the time you were served or at any subsequent time did you owe the defendant any money or
were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money
or were liable to him for any reason?
Defendant had account 537076911 with a balance of $31.56 at time served. The account
is held jointly with Steve M Palm of 82 Linda Dr, Mechanicsburg. The account is
a direct deposit account. Defendant is eligible for $300 allowable exemption.
1 a. If the answer to Interrogatory I is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities.
See answer to question I.
2. At the time you were served or at any subsequent time was there in your possession, custody or
control of yourself and one or more other persons any property of any nature owned solely or in part by the
defendant.
See answer to question 1.
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
See answer to question 1.
4. At the time you were served or at any subsequent time did you hold as fiduciary any property in
which the defendant had an interest?
No
5. At any time before or after you were served, did the defendant transfer or deliver any property to
you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof?
Defendant made deposits into the above referenced account in the ordinary course prior
to service, none of which were at the direction of Commerce Bank.
6. At any time after you were served did you pay, transfer, or deliver any money or property to the
defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant
against you?
No
7. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which funds are deposited electronically on a
recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or
attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption,
the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring
basis.
See answer to question 1.
8. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including any
otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account.
See answer to question 1.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: '
William T. Molczan, E ire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05331868
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is (VI , tii o < L
(Name)
L `z i 5Q?> C c kST of 1 ?,u;Y??iCc'L f Nf L, A garnishee herein,
(Title) (Company)
that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief.
I ATURE)
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-04628 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
CACV OF COLORADO LLC
VS
BROWN CORINA
And now SHARON LANTZ
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0008:43 Hours, on the 11th day of July , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
, in the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 20 NOBLE BLVD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JONATHAN CARBAUGH (ASST MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within COMPLAINT & NOTICE
the contents there of known to His .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
Sworn and Subscribed to
true
and made
So answ s•
.00 060C 01
.00 ?
.00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00 1 9,
007/18/2007
before me this day of B?
A.D
ti
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CACV OF COLORADO LLC
Plaintiff
VS.
CORINA BROWN
Defendant
COMMERCE BANK
Garnishee
No. 06-4628- CIVIL TERM
PRAECIPE TO SETTLE, DGeON94SU&
& END AS TO THE GARNISHEE
COMMERCE BANK ONLY
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt
PA I.D #42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR45331868
ell
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CACV OF COLORADO LLC
Plaintiff
VS.
CORINA BROWN
Defendant
COMMERCE BANK
Garnishee
Civil Action No. 06-4628- CIVIL TERM
PRAECIPE TO SETTLE DISCONTINUE AND END
AS TO THE GARNISHEE, COMMERCE BANK, ONLY
TO THE PROTHONOTARY OF COUNTY:
Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, COMMERCE BANK,
only, upon the records of the Court and mark the cost paid.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James C. Waj
PA I.D #42
WEL ,
2718 Ko r!
& REIS CO., L.P.A.
436 Sev th Av ue
Pittsb , PA 5219
(412)434-79
Sworn to and subscribed
Before me the ?S
Day of AUGUST
_., 007
RY PU IC
1868
,ok
O `.
cn
Ca
" ; sworn according to law, states
Y o Mine, Sheriff, who beingdulX
OFF,
this writ is returned STAYED, DUF- t0 .BAANKRUPTCY.
i. -j 20 2: b
Sheriff s Costs: Advance Costs: 150.00
Sheriffs Costs: 120.51
Docketing $ 18.00 29.49
Poundage 2.37
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 10/03/07
Mileage 8.64
Surcharge 40.00
Levy 40.00
Post Pone Sale
Garnishee 9.00
Postage
TOTAL $
120.51 //
So Answers;
R. Thomas Kline, Sheriff
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